Privacy Policy
Effective Date: April 19, 2023
This Privacy Notice explains how we collect, use, disclose, and otherwise process personal information in connection with our services. This Privacy Notice is not a contract and does not create any legal rights or obligations.
Who We Are
FirstDay Foundation (‘we’ or ‘us’ or ‘our’) gathers and processes personal information in accordance with this privacy notice and in compliance with the relevant data protection regulations and law. This notice provides you with the necessary information regarding your rights and obligations, and explains how, why, and when we collect and process your personal data.
This Privacy Notice Outlines
- What kinds of personal information we collect and why we collect it
- How we use that personal information
- With whom we disclose or share personal information
- Your legal rights regarding how we collect, use, and share personal information; and
- How we protect your information
Note that FirstDay Foundation does not sell personal information.
What is Personal Information?
When we use the term “personal information” or “personal data” in this Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.
Collection Points of Personal Data
This Privacy Notice applies to information we collect:
- Through the FirstDay Foundation websites operated by FirstDay Foundation
- Through other websites and online services that we own, operate, or make available and that link to this Privacy Notice
- When you donate
- When you apply for a job with FirstDay Foundation
- Through other general inquiries we receive through other means, including postal mail, electronic mail, telephone requests, and in person
- While providing services to our beneficiaries
Information That We Collect
FirstDay Foundation processes personal information to meet our legal, statutory, and contractual obligations and to provide our services. We will never collect any unnecessary personal data and do not process personal information in ways that are not specified in this notice.
| Individuals/Groups | Types of Data |
| Refugees | Full Name, Address, Contact Details, Refugee Status, Medial Information, Current and Former Employee Information, Financial Information, Marital Status, Location of Separated Family Members, |
| Minors | Full Name, Name of Primary Caregiver, Relationship to Minor, Contact Information, Medical Information, Financial Information |
| NGOs, Non-Profits, Charities, Donors | Full Name, Address, Contact Details, Financial Information, Services Provided, |
| Agencies | Agency Name, Staff Name, Job Title, Contact Information, Address, |
| Foster Families | Full Name, Address, Contact Information, Financial Information |
| FirstDay Foundation Staff Members | Full Name, Address, Financial Information, Contact Information, Identification Badge, Emergency Contact Information, |
| FirstDay Foundation Applicants | Full Name, Contact Information, Address |
| FirstDay Foundation Visitors | Full Name |
Special Category Personal Data
To support services to beneficiaries, we may collect or otherwise process especially sensitive personal data. This “Special Category” personal data may include:
- Race and ethnic origin
- Religious or philosophical beliefs
- Political opinions
- Trade union memberships
- Biometric data used to identify an individual
- Genetic data
- Health data
- Data related to sexual preferences, sex life, and/or sexual orientation
FirstDay Foundation may process this data as necessary to identify and provide the services required by beneficiaries and staff members.
Personal Data of Children and Minors
To support services to beneficiaries, we may collect or otherwise process the personal data of children. FirstDay Foundation may process this data as necessary to identify and provide the services required by children who are beneficiaries. We do not process this data for marketing purposes or creating personality or user profiles. How We Use Your Personal Data (Legal Basis and Legitimate Interests for Processing)
FirstDay Foundation takes your privacy very seriously and will never disclose, share, or sell your data without your consent, unless required to do so by law. We only retain your data for as long as is necessary and for the purposes specified in this notice. Where you have consented to receiving promotional offers and marketing, you are free to withdraw consent at any time. The purposes and reasons for processing your personal data are detailed below
| Purpose | Activity Description |
| Foster Care Orientation | Identification and onboarding of prospective foster parents |
| Donations | Financial support of FirstDay Foundation mission |
| Meet Refugee Needs | Healthcare, Housing, Legal, Behavioral and Mental Health, Childcare, Clothing, Social Connectedness, Financial Needs, Proper Nutrition, Furniture and Appliance, Resource Coordination |
| IT | Electronic Monitoring for Safety and Security |
| Operations | Staff Member Identification, Visitor Identification, Accidents, Vehicles |
| HR | Recruiting Activities, Benefits, Compensation, Background Checks, Hiring Requirements, Personnel Records |
| Insurance | Securing insurance to protect those who help deliver our services |
| COVID-19 Immunization | Tracking and reporting of required immunizations |
Cookies and Other Tracking Technologies
Cookies are small data files that are stored on your computer that allow us and our third-party partners and service providers to collect certain information about your interactions with our email communications, websites, and other online services. We and our third-party partners and providers may also use other, related technologies to collect this information, such as web beacons, pixels, embedded scripts, location-identifying technologies, and logging technologies (collectively, “cookies”).
If you would prefer not to accept cookies, most browsers will allow you to:
- Change your browser settings to notify you when you receive a cookie, which lets you choose whether to accept it,
- Disable existing cookies, or
- Set your browser to automatically reject cookies.
Please note that doing so may negatively impact your experience using our online services, as some features and services on our online services may not work properly. Depending on your device and operating system, you may not be able to delete or block all cookies. In addition, if you want to reject cookies across all your browsers and devices, you will need to do so on each browser on each device you actively use. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.
One or more of our websites collect data to track and report website traffic data. You can learn more about Google’s practices with Google Analytics by visiting Google’s privacy policy here. You can also view Google’s currently available opt-out options here.
Your Rights
You have the right to access any personal information that FirstDay Foundation processes about you and to request information about:
- What personal data we hold about you
- The purposes of the processing
- The categories of personal data concerned
- The recipients to whom the personal data has/will be disclosed
- How long we intend to store your personal data for
- If we did not collect the data directly from you, information about the source
If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to update/correct it as quickly as possible. In cases where we are unable to honor this request, we will notify you.
You also have the right to request erasure of your personal data or to restrict processing in accordance with data protection laws. In cases where we have made your personal data public, you have the right to request that we take reasonable measures to ensure that this data, including links, copies, and replications, is erased by third parties.
You have the right to object to any direct marketing from us and to be informed about any automated decision-making that we use.
In cases where we process your personal data under your consent, you have the right to withdraw this consent at any time.
In cases where we process your personal data under your consent or based on contractual necessity, you have the right to request that we provide this data in a structured, commonly used, machine-readable format. You may request that we transmit this data directly to you, or directly to a recipient of your choice, where technically feasible.
If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the relevant request. This helps ensure that your data is protected and kept secure.
We commit to fulfilling valid requests within timelines specified by applicable regulations and within one month of receipt of your request. We may charge a small administrative fee when requested for multiple copies of personal data or handling of requests that we believe to be manifestly unfounded. If FirstDay determines that an administrative fee applies, full settlement in the determined amount must be complete before any requests will be fulfilled.
Exceptions to Fulfillment of Data Subject Rights Requests
We will take every measure to evaluate and fulfill valid requests. However, we may refuse to fulfill a request in some circumstances, including:
- When we are unable to verify your identity, or the validity of a request made on your behalf
- Requests that are manifestly unfounded or excessive
- Circumstances in which fulfilling a request may prohibit the exercise of the right of freedom of expression
- When a legal obligation prohibits us from fulfilling the request
- When the request runs counter to public interest or public health
- When we must maintain the personal data for archiving, scientific, or historical research purposes
- For the establishment of, exercise of, or defense against legal claims
Sharing and Disclosing Your Personal Information
We do not share or disclosure any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement. FirstDay Foundation may use third parties to process personal data in support of services and business functions; however, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, and applicable data protection laws and confidentiality and security measures.
FirstDay Foundation will establish and maintain policies, procedures, and contractual agreements to comply with applicable privacy laws and regulations pertaining to cross-border transfers of data. FirstDay Foundation verify appropriate cross-border transfer mechanisms (e.g., Standard Contractual Clauses or Binding Corporate Rules) are in place when engaging in cross-border data transfers.
FirstDay Foundation may collect personal data through Facebook, including (but not limited to) using forms as a collection mechanism. For more information on how Facebook (and its parent organization, Meta) protects personal data, see https://www.facebook.com/privacy/policy/.
FirstDay Foundation leverages Salesforce to manage the delivery of beneficiary services. For more information on how Salesforce protects personal data, see https://www.salesforce.com/company/privacy/.
Safeguarding Measures
FirstDay Foundation takes your privacy seriously and we take every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorized access, alteration, disclosure, or destruction and have implemented appropriate security measures, including:
- Technical Security Measures, including Firewalls, VPNs, Access Control Lists, Endpoint defense and protection, automatic email encryption, role-based access controls, and third-party scanning
- Administrative measures, including Cyber Awareness, Phishing Training, Insider Threat, Privacy Governance and Training.
Consequences of Not Providing Your Data
You are not obligated to provide your personal information to FirstDay Foundation. However, where this information is required for us to deliver our services or enable you to support our mission, we will not be able to offer some / all our products or services without it.
How Long We Keep Your Data
FirstDay Foundation only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations.
Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.
Lodging an Inquiry or Complaint
To register an inquiry about the processing of your personal data, or to request more information about this Notice or our processing of personal data, please contact Privacy@FirstDay.Foundation
FirstDay Foundation only processes your personal information in compliance with this privacy Notice and in accordance with the relevant data protection laws. If, you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with your data protection regulator or supervisory authority.
You may also contact us by postal mail at the following address:
FirstDay Foundation
Attn.: Data Privacy
1506 Bexar Crossing
San Antonio, TX 78232
